2018 Annual Report - Rules & Law

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2018 Annual Report - Rules & Law

CGA negotiates wins for renewables

CGA engages in state regulatory and resource planning processes to support the region’s transition to renewable energy and carbon reduction, reduce burdensome regulation, and ensure grid and other issues are addressed in a timely manner.


  • In Missouri, we successfully advocated that the Certificate of Convenience and Necessity provision be removed from a final rule.  This reduced regulatory requirements for developers when constructing wind and solar facilities.  
  • CGA was involved in Ameren’s 2017 Integrated Resource Plan (IRP) and Green Choice Tariff program negotiations.  With the IRP, we argued that the cost of utility-scale wind and solar resources used by Ameren Missouri in its 2017 IRP were too high, and proposed improved cost estimates.  Ameren Missouri acknowledged that there was room for improvement in their cost estimates and agreed to adopt our proposals in their update of the plan that occurs annually.
  • Ameren Missouri wanted to cap the Green Choice tariff program at 400 MW.  We negotiated the addition of a provision to the program’s tariff that established a procedure for increasing the amount of wind beyond 400 MW.
  • In Illinois, we demonstrated that the Adjustable Block Program was likely to use all of the RPS budget, and argued for changes that would increase the procurement of 15 year RECs; arguing that money that would be spent on 1 year spot procurements instead be used to procure 15 year RECs. 
  • CGA participated in a Stakeholder workgroup convened by the MN PUC to revise the state’s interconnection rules governing generator interconnection to the distribution system, including storage.  In addition, we submitted several sets of comments on the proposed rules.  The MN PUC approved these rule changes. 

Earlier Wins

  • In 2017, CGA provided industry input on a proposal by the North Dakota Public Service Commission to modify their administrative rules governing decommissioning of wind project, resulting in significant improvements to their initial proposal.

  • In 2017, the Illinois Power Authority adopted CGA’s proposal to procure more long term wind RECs (by 1 million RECs) than what was required under the Future Energy Jobs Act to take advantage of the federal Production Tax Credit prior to its expiration.